Pilots Association Calls for One Level of Safety
for Lithium Battery Shipments

By
Steve Hall

March 8, 2013 - The Air Line Pilots Association,
Int’l (ALPA) urged the Pipeline and Hazardous
Materials Safety Administration (PHMSA) to adopt
more stringent regulations over the air
transportation of lithium batteries and align
them with current International Civil Aviation
Organization’s (ICAO) requirements. ALPA’s
written comments responded to PHMSA’s recent
Notice of Proposed Rulemaking (NPRM) regarding
the air transportation of lithium batteries.

In addition, ALPA released a new primer on the
safety considerations of air shipments of
lithium batteries. The paper details the
deficiencies with current dangerous goods
regulations in the United States and offers
recommendations on how ICAO and PHMSA can
implement additional safeguards.

“ALPA has repeatedly raised questions about the
safety and the potential fire hazards associated
with shipping lithium batteries by air,” said
Mark Rogers, director of ALPA’s Dangerous Goods
Program. “The danger is increased as lithium
battery fires may be difficult to extinguish in
the best of circumstances, much less tens of
thousands of feet in the air. We strongly
believe that the ICAO requirements provide
greater safety for pilots and the traveling
public.”

The ICAO provisions incorporate new requirements
for packages containing more than eight cells or
two batteries, including training for the
shipper and operator, dangerous goods labels,
acceptance checks, preloading and unloading
inspections, and inclusion on the information
given to the pilot-in-command. Current U.S.
regulations allow exceptions for a large number
of consumer batteries in a single package, and
any number of packages on an airplane. These
batteries could be transported without a flight
crew ever being aware of the potential risk.

ALPA cites one notable occurrence in September
2010—two United Parcel Service pilots lost their
lives when they reported a main-deck fire
shortly after takeoff, but crashed while trying
to return to the airport. On board the plane
were 80,000 lithium batteries. Although the
investigation continues, the real risks of
lithium batteries cannot be ignored.

On
February 7, 2006, a United Parcel Service Company flight
1307, a McDonnell Douglas DC-8-71F, N748UP, landed at
its destination airport, Philadelphia International
Airport, Philadelphia, Pennsylvania, after a cargo smoke
indication in the cockpit. The captain, first officer,
and flight engineer evacuated the airplane after
landing. The flight crewmembers sustained minor
injuries, and the airplane and most of the cargo were
destroyed by fire after landing.

The National Transportation Safety Board determined the
probable cause of this accident to be an in-flight cargo
fire mostly likely caused by
lithium batteries.
Contributing to the loss of the aircraft were the
inadequate certification test requirements for smoke and
fire detection systems and the lack of an on-board fire
suppression system. The NTSB concluded that flight
crews on cargo-only aircraft remain at risk from
in-flight fires involving both primary and secondary
lithium batteries.

The NTSB in this case recommended that aircraft
operators implement measures to reduce the risk of
primary lithium batteries becoming involved in fires on
cargo-only aircraft, such as transporting such batteries
in fire resistant containers and/or in

restricted quantities at any single location on the
aircraft.

The NTSB recommended that carriers analyze the causes of
all thermal failures and fires involving secondary and
primary lithium batteries and, based on this analysis,
take appropriate action to mitigate any risks determined
to be posed by transporting lithium batteries, including
those contained in or packed with equipment, on board
cargo and passenger aircraft as cargo; checked baggage;
or carry-on items.

ALPA also contends that, in addition to simply providing
the safest means of transporting these goods, having
different and unequal standards of safety could
jeopardize the FAA’s ability to enforce compliance—even
for international shipments. It could also cause
logistical problems for shippers guiding a shipment of
lithium batteries through the United States to an
international destination.

“We will continue to call for even stricter
guidelines for the transportation of lithium
batteries that go beyond ICAO’s provisions,” added
Capt. Lee Moak, ALPA’s president. “But in the
meantime, we recommend that PHMSA immediately
withdraw its recent rulemaking and issue a final
rule to align with ICAO’s technical instructions for
the safe air transport of lithium batteries.”